claimed in the '519 Patent, including, without limitation, products such as External USBModem, Data Fax PCI, USR5637, Internal Modem Daughter Card, PCI Modem, Dell StudioHybrid, and others (the "'519 Accused Instrumentalities").12.
Defendant was made aware of the '519 Patent and their infringement thereof atleast as early as the filing of this Complaint.13.
At least as of the filing of this Complaint, Defendant is, on information and belief, inducing infringement of one or more claims of the '519 Patent by, without limitation,making, using, importing, selling and/or offering for sale the '519 Accused Instrumentalitiesfor use by customers and others and also providing those customers and others with technicalsupport and services, as well as detailed explanations, instructions and information as toarrangements, applications and uses of the '519 Accused Instrumentalities that promote anddemonstrate how to use the '519 Accused Instrumentalities in a manner that would infringethe '519 Patent.14.
Upon information and belief, at least as of the filing of this Complaint, Defendantspecifically intended to induce infringement by its customers and others by at least the acts setforth in paragraph 13, knowing that such acts would cause infringement and/or were willfully blind to the possibility that their inducing acts would cause infringement. Upon information and belief, Defendant's customers and others have infringed and are continuing to infringe the '519Patent.15.
Telecomm has been harmed by Defendant's infringing activities.
INFRINGEMENT OF U.S. PATENT NO. 5,600,712
Telecomm repeats and realleges the allegations of paragraph 1 through 15 asif fully set forth herein.